In brief
On 13 July 2026, the Monetary Authority of Singapore (MAS) published an Information Paper setting out its observations and supervisory expectations to guide digital payment token service providers (DPTSPs) in implementing their anti-money laundering, countering the financing of terrorism, and countering proliferation financing (AML/CFT/CPF) controls in key areas ("Information Paper"). The information paper may be viewed here.
The paper supplements existing AML/CFT/CPF requirements and should be read in conjunction with MAS Notice PSN02 ("Notice") and its accompanying Guidelines ("Guidelines"). DPTSPs are expected to conduct a gap analysis against the paper (having regard to their enterprise-level risk profile) and, where gaps are identified, implement timely remediation under close Board and senior management oversight.
The Information Paper sets out MAS' supervisory expectations in the following areas:
- Assessment of Risks Arising from New Products
- Enhanced Customer Due Diligence Measures
- Value Transfer Requirements
- Ongoing Monitoring
- Screening
- Due Diligence on Partners and Outsourced Providers
- Training and Staff Expertise.
In summary, MAS observed that the DPT sector presents heightened ML/TF risks (given the pseudonymous and cross-border nature of DPT transactions) and outlined the expectation for DPTSPs to ensure that their AML/CFT/CPF risk detection capabilities and controls remain effective to detect, assess, and mitigate these risks. DPTSPs should assess the effectiveness of existing frameworks and controls, take timely and risk-proportionate steps to address any identified gaps, and ensure that relevant learnings are incorporated in their P&Ps and shared with staff to raise ML/TF risk awareness across the organisation. MAS also outlined the expectation for Boards and senior management to maintain direct, demonstrable oversight of the ML/TF risks faced by DPTSPs and ensure that AML/CFT/CPF risk mitigation remains a key priority.
If you have any questions on how this may impact your business or operations, please feel free to reach out to us.
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